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Online harms addressed
Territorial scope
Penalties and enforcement
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29 Sep 2025
Insight
Key online safety measures and status
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Key online safety measures |
Status |
Additional commentary regarding status |
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Law |
Received Royal Assent on 26 October 2023. Consists of framework of statutory duties to be supplemented by secondary legislation and Codes of Practice. Phased approach to application of the Act, with first tranche of measures (regarding illegal harms) coming into force in March 2025. |
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The Online Safety Act 2023 (Category 1, Category 2A and Category 2B Threshold Conditions) > |
Law |
In force from 27 February 2025. Outlines the thresholds for categorisation under the Act which determines whether service providers are subject to additional duties to implement additional safety measures to protect users from online harms. |
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The Online Safety Act 2023 (Qualifying Worldwide Revenue) Regulations 2025 > |
Law |
In force from 8 October 2025. Confirms how "qualifying worldwide revenue" will be determined for the purposes of imposing fines for breach of obligations under the Act. |
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Illegal content Codes of Practice for user-to-user services > |
Codes of Practice |
In force from 17 March 2025. Outlines recommended measures for user-to-user services to comply with their duties to take proportionate measures to prevent users from encountering illegal content on the service, including mitigating the risk of harm to individuals, under section 10 of the Act Service providers are not required to implement the recommendations set out in the Codes, but must implement alternative measures if they choose not to. |
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Codes of Practice |
In force from 17 March 2025. Outlines recommended measures for search services to comply with their duties to take proportionate measures to prevent users from encountering illegal content on the service, including mitigating the risk of harm to individuals, under section 27 of the Act. Service providers are not required to implement the recommendations set out in the Codes, but must implement alternative measures if they choose not to. |
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Protection of Children Code of Practice for user-to-user services > |
Code of Practice |
In force from 25 July 2025 Outlines recommended measures for user-to-user services which are likely to be accessed by children to comply with their duties under section 12 of the Act. Section 12 imposes a duty to take proportionate measures to prevent children from accessing content that is harmful to them and manage the risk of harm to children. Service providers are not required to implement the recommendations set out in the Codes, but must implement alternative measures if they choose not to. |
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Protection of Children Code of Practice for search services > |
Code of Practice |
In force from 25 July 2025 Outlines recommended measures for search services to comply with their duties under section 29 of the Act. Section 29 imposes a duty to take proportionate measures to prevent children from accessing content that is harmful to them and manage the risk of harm to children. Service providers are not required to implement the recommendations set out in the Codes, but must implement alternative measures if they choose not to. |
Key concepts
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Key takeaways
Proportionate tiered risk-based approach in terms of duties applicable to different categories of platforms
More comprehensive requirements for in-scope services that have a higher reach and present a higher risk
More stringent approach for children with regard to lawful but harmful content
More proactive approach required to compliance, compared to the existing reactive approach
Elevated importance of user choice and terms and conditions as part of 'triple shield' approach
Requirement to balance compliance with online safety duties with free speech considerations
Key contacts
Hayley Brady
Partner, London
Claire Wiseman
Knowledge Lawyer, London
James Balfour
Senior Associate, London
Rachel Kane
Senior Associate, London
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Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.